ALI-ABA Course of Study Charitable Giving Techniques

Similar documents
ALI-ABA Course of Study Estate Planning for the Family Business Owner

ALI-ABA Course of Study Planning Techniques for Large Estates April 20-24, 2009 New York, New York PROGRAM FACULTY PARTICIPANTS VOLUME 1

CHARITABLE REMAINDER TRUSTS

ALI-ABA Topical Courses Advanced Estate Planning Practice Update: Winter 2011 February 10, 2011 Video Webcast

ALI-ABA Topical Courses Advanced Estate Planning Practice Update: Fall 2011 September 22, 2011 Video Webcast

ALI-ABA Video Law Review Advanced Estate Planning Practice Update: Winter 2009 February 5, 2009 Live Video Webcast

ALI-ABA Course of Study Charitable Giving Techniques

ALI-ABA Telephone Seminar/Audio Webcast State Unclaimed Property Laws: Best Practices for Compliance October 20, 2009 TABLE OF CONTENTS

.02 Apportionment of the Annuity Amount in the Discretion of the Trustee.

TABLE OF CONTENTS. Page

Division Of Charitable Remainder Trust after Divorce: A Model Memorandum

ALI-ABA Course of Study Fundamentals of Employee Benefits Law March 5-7, 2009 Orlando, Florida TABLE OF CONTENTS

ALI-ABA Course of Study Estate Planning in Depth

Planning Techniques for Large Estates 2018

A Highly Practical Discussion of Lead Trusts Chicago Council on Planned Giving Annual Symposium Tim Prosser and Paul Williamson CLT

Employee Benefit Plans of Tax-Exempt and Governmental Employers Gregory F. Jacob O Melveny & Myers LLP

TABLE OF CONTENTS FACULTY PARTICIPANTS FACULTY BIOGRAPHIES STUDY MATERIALS

ALI-ABA Topical Courses Worker Classifications: New IRS Settlement Program & Other Winning Strategies November 10, 2011 Video Presentation

ALI-ABA Course of Study Planning Techniques for Large Estates November 16-20, 2009 San Francisco, California

ALI-ABA Live Video Webcast Health Plans Update: HIPAA, Cafeteria Plans and Other Welfare Plan Issues February 25, 2009 TABLE OF CONTENTS

Representing Estate and Trust Beneficiaries and Fiduciaries 2018

Sophisticated Charitable Giving: Thirteen Charitable Planning Issues

December th year

Current and Year-End Estate Planning Issues

Understanding Charitable Trusts

GST and Form 709: Fundamentals of Generation-Skipping Transfer Tax Reporting

Charitable Trusts David Nunheimer The Small Business & Estate Planning Law Group 26 George Ryder Road West Chatham, MA

CLIENT ALERT - TAX-FREE DIRECT CHARITABLE/IRA DISTRIBUTIONS

CHARITABLE REMAINDER TRUST GIFT PLANNING.... including the FULL-MONTY CRUT CONRAD TEITELL, LL.B., LL.M*

ALI-ABA Course of Study Planning Techniques for Large Estates. April 28 - May 2, 2008 New York, New York

An Introduction To Actuarial Valuations

ALI-ABA Topical Courses Fiduciaries Facing New Investment Advice Rules, Health Reform & Changing Fee Pressures June 9, 2010 Video Webcast

ALI-ABA Course of Study Planning Techniques for Large Estates April 26-30, 2010 New York, New York FACULTY PARTICIPANTS VOLUME 1

The Doctor Is In; School Is In Session: Answers on the Use of the Gift Tax Medical and Tuition Expense Exclusion

ALI-ABA Course of Study Accountants' Liability: Litigation and Issues in the Financial Crisis July 9-10, 2009 Chicago, Illinois

Advanced Commercial Finance 2018:

April rd year. TAX REFORM: SENATE FINANCE COMMITTEE SOLICITS YOUR OPINION Urge permanent and expanded Charitable IRA April 15 deadline

To learn more call or visit cancer.org / npan Charitable Remainder Trusts (CRTs): Back to the Future A Donor creates a trust, in which

ALI-ABA Course of Study The Subprime Mortgage Crisis: From A to Z September 18-19, 2008 Washington, D.C. PROGRAM FACULTY PARTICIPANTS

Charitable Giving Without Trusts Deduction Rules And Techniques

2019 TE/GE COUNCIL EMPLOYEE PLANS ANNUAL MEETING

Converting Ordinary Income Into Capital Gains Using The Early Termination Of Private Trusts And Charitable Remainder Trusts

ALI-ABA Topical Courses. Marital Deduction & Credit Shelter Trusts: Planning Techniques for Drafting in Changing Times November 2, 2009 Video Webcast

Disclaimers The information and/or the materials provided as part of this program are intended and provided solely for informational and educational p

Demystifying Gifts Involving LLCs

2017 JOINT TE/GE COUNCIL EMPLOYEE PLANS & EXEMPT ORGANIZATIONS ANNUAL MEETING. Register at: 2017 REGISTRATION

RETIREMENT ACCOUNTS. REQUIRED distribution rules --

GIFT ACCEPTANCE POLICY

SUCCESSION & PERSONNEL CHANGE REQUEST FORM

ALI-ABA Course of Study Estate Planning for the Family Business Owner

ALI-ABA Course of Study Going International: Fundamentals of International Business Transactions. December 7-9, 2006 Washington, D.C.

Leaving a Legacy. Your Guide to Charitable Giving

Donor Advised Funds. Forms Booklet

Internal Revenue Service CC:PA:LPD:PR (Notice ), Room 5203 P.O. Box 7604 Ben Franklin Station, Washington, DC 20044,

International Trust and Estate Planning

GEORGIA STATE UNIVERSITY FOUNDATION, INC.

ABA. Title Insurance Litigation Committee Spring 2009 Seminar & Meetings. March 6, 2009 The Fairmont Olympic Hotel Seattle, WA

The conference is pleased to have the University of San Diego School of Law as a co-sponsor of this year s conference.

Estate Planning for the Family Business Owner

Running the Numbers: An Economic Analysis of GRATs and QPRTs

GIFT AND ESTATE TAX PLANNING GUIDE

Charitable Gift Annuities

Attorney General Guidance on the New York Prudent Management of Institutional Funds Act

ALI-ABA Course of Study. Estate and Distribution Planning With Qualified Plans & IRAs

THE AMERICAN LAW INSTITUTE Continuing Legal Education. Estate Planning for the Family Business Owner

Life Insurance Company Products

1500 Pennsylvania Avenue, NW 1111 Constitution Ave, NW Washington, DC Washington, DC Constitution Ave, NW Internal Revenue Service

TABLE OF CONTENTS PROGRAM FACULTY PARTICIPANTS FACULTY BIOGRAPHIES STUDY MATERIALS

Conference on Insurance and Financial Services Industry Litigation

CASTLE BRANDS INC Filed by CAMULOS CAPITAL LP

STEP INTERNATIONAL TAX AND ESTATE PLANNING FORUM

Proposed Regulations Providing Additional Examples of Private Foundation Program-Related Investments

Employee Benefit Plans of Tax-Exempt and Governmental Employers

Charitable Planning in a New Era

Tax Bulletin: Effectively Using a QPRT Strategy in Your Estate Plan

Day 1 March 26, 2015:

Rochelle L. Haller Principal

CHARITABLE PLANNING WITH RETIREMENT ACCOUNTS: STRATEGIES, TRAPS AND SOLUTIONS PRESENTER: CHRISTOPHER R. HOYT

ANITA J. SIEGEL, ESQ. Siegel & Bergman, LLC 365 South Street Morristown, NJ Fax

VICTORIA B. BJORKLUND JENNIFER I. GOLDBERG

PRIVATE WEALTH & 2015 TAXATION INSTITUTE

Life Income Gifts 4/19/2016. How a Life Income Gift Works. Rebecca E. Dupras, Esq. Vice President of Development Silicon Valley Community Foundation

ALI-ABA Course of Study Fundamentals of Employee Benefits Law May 16-18, 2012 Washington, D.C.

BILL & MELINDA GATES FOUNDATION TRUST. Financial Statements. December 31, 2017 and (With Independent Auditors Report Thereon)

Charitable Investment Advisor Program Investment Policies and Guidelines

MAKE YOUR CHARITABLE ESTATE PLAN GREAT AGAIN Charitable Planning with Retirement Accounts: Strategies, Traps & Solutions

Donating Retirement Assets. Dr. Russell James Texas Tech University

2018 JOINT TE/GE COUNCIL EMPLOYEE PLANS & EXEMPT ORGANIZATIONS ANNUAL MEETING. University of Baltimore Baltimore, Maryland February 22-23, 2018

ALI-ABA Course of Study Fundamentals of Estate Planning June 11-12, 2009 Boston, Massachusetts. Estate Planning With Qualified Plans and IRAs

FARM AND RANCH INCOME TAX/ESTATE AND BUSINESS PLANNING

RETIREMENT BENEFITS: SOPHISTICATED ESTATE PLANNING

THE AMERICAN LAW INSTITUTE Continuing Legal Education. Estate Planning in Depth

Section 72.--Annuities; Certain Proceeds of Endowment and Life Insurance Contracts

BROOKINGS PARTNERS. TOGeTher, OUr IMPaCT IS GreaT Drs. harriet Switzer and David Cronin Sharing the Gift of Education

ESTATE AND TAX PLANNING AND CHARITABLE GIVING

INCOME TAX DEDUCTIONS FOR CHARITABLE BEQUESTS OF IRD

Presented by Richard D. Cirincione 677 Broadway Albany, NY Direct: Fax:

33rd annual Federal Tax Institute

FORM ADV UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS

BROOKINGS PARTNERS YEAR-END GIFT PLANNING GUIDE. Dr. Ann Johanson Going the Distance for Students RECOGNIZING THE IMPORTANCE OF PLANNED GIFTS

Transcription:

ALI-ABA Course of Study Charitable Giving Techniques Cosponsored by the ABA Section of Real Property, Trust and Estate Law and the ABA Section of Taxation July 9-10, 2009 Seattle, Washington PROGRAM FACULTY PARTICIPANTS TABLE OF CONTENTS Page xiii xv STUDY MATERIALS 1. Setting the Stage for Charitable Giving 1 By Martin Hall and Jerry J. McCoy Table of Contents 2 Study Materials 3 2. Charitable Remainder Trusts: Charity Can Begin at Home 59 By Lawrence P. Katzenstein Study Materials 61 Appendix A: Memorandum re: section 7520 rate 90 Appendix B: Sample Charitable Remainder Annuity Trusts 93 Appendix C: Sample Charitable Remainder Unitrusts 96 3. Investment of Charitable Remainder Trusts in Institutional Endowment 101 Funds The Rulings By Martin Hall Exhibit A: Original Letter Rulings 104 Exhibt C: Redemption of Endowment Units Produces Capital Gain 110 Exhibit B: Backtracking on Lead Trusts 116 4. Commingling CRT Assets in Endowments By Pamela G. Yang 131 ix

5. Giving to the Private Foundation, Donor-Advised Fund and Supporting 137 Organization By Victoria B. Bjorklund Table of Contents 139 Study Materials 141 Exhibit A: Not More Than Incidental Benefits 175 Exhibit B: IRS Announcement 2007-87 176 Exhibit C: IRS Notice 2006-109 187 Exhibit D: Private Letter Ruling 9021066, Section 4941 200 Exhibit E: Matrix of Control 202 Exhibit F: Family Charities Shift Assets to Donor Funds 203 Exhibit G: Environmental Foundation Expires, as It Always Wanted 205 Presentation Slides 207 6. Charitable Lead Trusts 219 By Edward Jay Beckwith Table of Contents 221 Study Material 223 Appendix A: Rev. Proc. 2007-45 282 Appendix B: Rev. Proc. 2007-46 302 7. The Use of Life Insurance in Charitable Planning 311 By Lawrence Brody Table of Contents 313 Study Materials 315 Exhibit A: Charitable Life Insurance Guidelines 379 8. Charitable Giving Tax Pitfalls: Avoiding; Climbing Out; Cyanide 383 Capsule? By Conrad Teitell Table of Contents 384 Study Materials 387 9. Charitable IRA Rollover in 2010? 2011? 511 By Professor Christopher R. Hoyt Study Materials 513 Presentation Slides 582 10. Charities as Beneficiaries Post-Mortem Issues 597 By Lawrence P. Katzenstein Study Materials 599 Appendix A: Example of Code to Calculate Interrelated Estate Tax 613 11. Charitable Tax-Planning for Closely-Held Businesses and Their Owners 621 By Professor Christopher R. Hoyt Study Materials 623 Presentation Slides 660 x

12. Questions for Developing Proposed Intake Guidelines for Acceptance by 671 Charity of Existing Life Insurance Policies; Questions Designed to Develop Proposed Administrative Guidelines for Life Insurance Policies Owned by Charity Insuring the Lives of Its Donors By Lawrence Brody Questions Designed to Develop Proposed Intake Guidelines for Acceptance by Charity of Existing Life Insurance Policies Insuring the Lives of Its Donors 673 Questions Designed to Develop Proposed Administrative Guidelines for Life Insurance Policies Owned by Charity Insuring the Lives of Its Donors 676 xi

2

ALI-ABA Course of Study Charitable Giving Techniques Cosponsored by the ABA Section of Real Property, Trust and Estate Law and the ABA Section of Taxation July 9-10, 2009 Seattle, Washington PROGRAM Thursday, July 9, 2009 7:30 a.m. Registration and Networking Session VIDEO WEBCAST SEGMENT A 8:30 a.m. Introductory Remarks 8:45 a.m. Basic Concepts: Deduction Rules and Non-Trust Planned Gifts Messrs. Hall and McCoy 10:15 a.m. Networking Break 10:30 a.m. Basic Concepts (cont.) 11:15 a.m. Charitable Remainder Trusts Mr. Katzenstein 12:30 p.m. Box Lunch and Keynote Address - Mr. Porter (not webcast or recorded) VIDEO WEBCAST SEGMENT B 1:45 p.m. Investment of Charitable Remainder Trusts in Institutional Endowment Funds Mr. Hall and Ms. Yang 2:45 p.m. Networking Break 3:00 p.m. Private Foundations, Donor-Advised Funds, and Supporting Organizations Mss. Bjorklund and Valas 4:15 p.m. Ethical Considerations in Planned Giving Faculty Panel 5:15 p.m. Adjournment for the Day Friday, July 10, 2009 7:30 a.m. Networking Session VIDEO WEBCAST SEGMENT C 8:00 a.m. Charitable Lead Trusts Mr. Beckwith 9:30 a.m. Networking Break 9:45 a.m. Use of Life Insurance in Charitable Giving Mr. Brody 10:45 a.m. Charitable Giving Tax Pitfalls; Avoiding; Climbing Out; Cyanide Capsule Mr. Teitell 11:45 a.m. Lunch Break xiii

VIDEO WEBCAST SEGMENT D 1:00 p.m. Use of Qualified Plans in Charitable Giving Professor Hoyt 2:00 p.m. Issues in the Administration of Estates with Charitable Beneficiaries Mr. Katzenstein 2:30 p.m. Networking Break 2:45 p.m. Charitable Planning Techniques with S Corporation Stock and Other Unusual Assets Professor Hoyt 4:00 p.m. Questions and Answers 4:15 p.m. Adjournment Total 60-minute hours of instruction: 13.5, including one hour of ethics 16 CPE credit hours in Taxation (group-live and group-internet-based program) xiv

ALI-ABA Course of Study Charitable Giving Techniques Cosponsored by the ABA Section of Real Property, Trust and Estate Law and the ABA Section of Taxation July 9-10, 2009 Seattle, Washington PLANNING CHAIR Lawrence P. Katzenstein, Esquire Thompson Coburn LLP Suite 3400 One US Bank Plaza 505 N. 7th Street St. Louis, MO 63101 KEYNOTE SPEAKER Drew Porter, Esquire Associate General Counsel The Bill and Melinda Gates Foundation P.O. Box 23350 Seattle, WA 98102 FACULTY Edward J. Beckwith, Esquire Baker & Hostetler LLP Washington Square Suite 1100 1050 Connecticut Avenue, NW Washington, DC 20036 Victoria B. Bjorklund, Esquire Simpson Thacher & Bartlett LLP 425 Lexington Avenue New York, NY 10017 Lawrence Brody, Esquire Bryan Cave LLP One Metropolitan Square Suite 3600 211 North Broadway St. Louis, MO 63102 Martin Hall, Esquire Ropes & Gray LLP One International Place Boston, MA 02110 xv

Professor Christopher R. Hoyt Professor of Law University of Missouri-Kansas City School of Law Law 1-200 5100 Rockhill Road Kansas City, MO 64110 Jerry J. McCoy, Esquire Law Office of Jerry J. McCoy P.O. Box 66491 Washington, DC 20035 Conrad Teitell, Esquire Cummings & Lockwood LLC Six Landmark Square Stamford, CT 06901 Ms. Karla D Alleva Valas Vice President of Compliance Fidelity Charitable Services Mail Zone: ZE7C 200 Seaport Boulevard Boston, MA 02210 Pamela G. Yang, CPA, CFA Senior Vice President Trust Operations & Investments Harvard Management Company 13 th Floor 600 Atlantic Avenue Boston, MA 02210 NOTE: Please go to www.ali-aba.org/cr011 for biographical information on this faculty. xvi